High Chairs Business Guidance and Small Entity Compliance ...

Federal law requires that high chairs comply with the Safety Standard for High Chairs, 16 CFR part 1231, and with additional requirements, including those of the Consumer Product Safety Improvement Act of 2008 (CPSIA). 

Manufacturers and importers of high chairs must certify in a Children's Product Certificate that the high chair complies with the Standard and the additional requirements after the high chairs have been tested for compliance at a CPSC-accepted, third party laboratory. These requirements are discussed below and at: www.cpsc.gov/BusinessEducation.

 

What is a high chair?

A high chair is a freestanding chair for a child up to 3 years of age that has a seating surface more than 15 inches above the floor and elevates the child normally for the purposes or feeding or eating.

 

What is the purpose of the High Chair Standard?

The Standard seeks to minimize injuries to children resulting from normal usage and reasonably foreseeable misuse or abuse of high chairs. Specifically, this Standard attempts to minimize injuries to children associated with tray disengagement, falls resulting when children stand up on the seat of a high chair, entrapment between the tray and the seat, and tip-overs.

 

Where can I find the High Chair Standard?

The Standard is published in the Code of Federal Regulations at 16 CFR part 1231. The Standard incorporates by reference ASTM F404-21, with certain modifications described below.

 

What are the specific requirements for high chairs in the High Chair Standard?

The principal performance requirements from the ASTM F404-21 High Chair Standard are:

• testing for high chair tray integrity
• testing for stability of the high chair to ensure that the chair cannot tip over in any direction
• testing for restraint-system strength and integrity
• testing for protruding protective components
• requirements for a passive crotch restraint, to prevent a child from sliding through the front or sides of the seat;
• a leg opening requirement to prevent children from sliding through these openings.

The specific requirements and descriptions of the tests for high chairs are in ASTM F404-21, which can be purchased from ASTM.

 

What are the additional requirements for high chairs required by the Consumer Product Safety Improvement Act?

High chairs are subject to requirements for surface coatings, lead content, small parts, testing and certification, registration cards, and tracking labels. These requirements are discussed below and at: www.cpsc.gov/cpsia:

• Surface Coating: High chairs may not be painted with paint that contains more than 0.009 percent (90 ppm) lead.
• Lead Content: High chairs cannot contain greater than 100 ppm (0.01 percent) of total lead content in any accessible component part.
• Phthalate Content Limits: Plasticized components of high chairs must not contain more than 0.1 percent of the following eight specified phthalates: di-(2-ethylhexyl) phthalate (DEHP), dibutyl phthalate (DBP), or benzyl butyl phthalate (BBP), diisononyl phthalate (DINP), diisobutyl phthalate (DIBP), di-n-pentyl phthalate (DPENP), di-n-hexyl phthalate (DHEXP), and dicyclohexyl phthalate (DCHP).
• Testing and Certification: High chairs, like all products that are designed or intended primarily for children 12 years of age or younger, must be tested by a CPSC-accepted, third party laboratory for compliance with applicable children's product safety regulations including the high chair standard. Based on that testing, a domestic manufacturer (or importer) of high chairs must issue a Children's Product Certificate indicating that the product complies with those regulations.
• Registration Forms: Each manufacturer of a high chair must (1) provide a postage-paid consumer registration form with each product and (2) keep records of consumers who register their products with the manufacturer. In addition, manufacturer's must add permanent markings to the product that state (3) the manufacturer's name and contact information, (4) the model name and number, and (5) the date of manufacture on each such product.
• Tracking Labels: High chairs must have a tracking label or other distinguishing permanent mark affixed to the product and its packaging. The tracking label shall be a permanent distinguishing mark on the product and its packaging, to the extent practicable, and must contain certain basic information, including the (1) name of the manufacturer or private label, (2) the location and date of manufacture, and (3) cohort information, such as a batch or run number.

To the extent that the information required to be marked on the product (by the tracking label requirement and the registration rule) is duplicative, you may combine the markings on the product to satisfy both requirements. Note that the tracking label requirement must also be marked on the product's packaging.

Where can I find additional information?

For more information on the requirements for high chairs, contact the U.S. Consumer Product Safety Commission’s:

• Office of Compliance (for specific enforcement inquires): e-mail: section15@cpsc.gov; telephone: (800) 638-2772.
• Small Business Ombudsman (for general assistance understanding and complying with CPSC regulations): e-mail: Please use our Contact Form, which is the best way to get a fast response; telephone: (888) 531-9070.

To obtain copies of ASTM F404-21, contact ASTM International at: www.astm.org or via telephone: (610) 832-9585.

This communication has been prepared for general informational purposes only.  This summary document does not, and is not intended to, constitute legal advice nor does it replace or supersede a manufacturer’s obligations to comply with all applicable laws, regulations, standards, or bans enforced by CPSC. This communication has not been reviewed or approved by the Commission, and does not necessarily represent their views. Any views expressed in this communication may be changed or superseded by the Commission.

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